FAA 

Exemption Rulemaking 

Section 333 

 Of The 

 FAA Reform Act Part 11 

Air Renditions Videography 

1294 Lynwood Dr. Novato, CA 94945 

415-895-6634

www.airrenditions.com

February 23, 2015

Attention: United States Secretary of Transportation 

Mr. Anthony R Foxx 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 CFR 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) 

(2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.409 (a) (2); 91.417 (a) 

& (b) 

Dear Mr. Secretary, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) 

and 14 CFR Part 11, Air Renditions Videography, a research developer and operator of Small 

Unmanned Aircraft Systems (“sUASs)” equipped to conduct aerial photography for industrial, 

motion picture, and television industry for scripted closed set filming, hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation 
of its sUASs (both Fixed-wing & Multi-Rotor), so long as such operations are conducted within 

and under the conditions outlined herein or as may be established by the FAA as required by 

Section 333.1

As described more fully below, the requested exemption would permit the operation of small, 

unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) 

limited 2) predetermined 3) controlled as to access and 4) would provide safety enhancements to 

the already safe operations in the industrial, film, and television production community presently 

using conventional and unmanned aircraft. Approval of this exemption would thereby enhance 

safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to 

“...establish requirements for the safe operation of such aircraft systems in the national airspace 

system.” Section 333 (c) of the Reform Act 

1 The conditions proposed by the applicant are drawn from Order 8900.1 CHG 0, Volume 3, 

Chapter 8- Issue a Certificate of Waiver for Motion Picture and Television Filming. 

The name and address of the applicant is: 

Air Renditions Videography 

1294 Lynwood Dr. Novato, CA 94947 

Attn: Tim Thompson Rich Galagaran 

Phone: 415-895-6634 

Email: richgalagaran@airenditions.com timthompson@airrenditions.com

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 
14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 

333 (a) through (c) of the Reform Act. This directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate safely in the national airspace system 

(NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In 

making this determination, the Secretary is required to determine which types of UASs do not 

create a hazard to users of the NAS or the public or pose a threat to national security in light of 

the following: 

The UAS’s size, weight, speed, and operational capability: 

Operation of the UAS in close proximity to airports and populated areas; and 

Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers. 

Reform Act §333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely 

in the national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system.” Id. §333 (c) (emphasis added).2

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined under 

§40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a 

current airworthiness certificate. The Administrator may grant an exemption from a requirement 

of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 

of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44704; 14 

CFR §91.203 (a) (1).

1 Applicant interprets this provision to place of the duty on the Administrator to not only process 

applications for exemptions under section 333, but for the Administrator to craft conditions herein for the 

safe operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the 

statutory requirements for approval. 
Air Renditions Videography’s sUASs are rotorcraft and fixed-wing aircraft, weighing 55 or 

fewer lbs. including sensor payload. They operate their rotorcraft, under normal conditions at a 

speed of no more than 20 knots and have the capability to hover, and move in the vertical and 

horizontal plane simultaneously. They operate their fixed-wing aircraft, under normal conditions 

at a speed of no more than 20 knots and primarily have the flight characteristics of traditional 

airplanes. They will manually operate only in VLOS and will operate only within the sterile area 

described in the Confidential: Flight Operations Manual (FOM) attached as Exhibit 

1 (hereinafter “the Manual”).3 Adherence to the Manual will insure that the sUAS will “not 

create a hazard to the national airspace system or the public.” 4

Given the small size and weight of the sUAS involved and the restricted sterile environment 

within which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, 

allow commercial operations of sUASs to commence immediately. Also due to the size of the 

sUASs and the restricted areas in which the relevant sUAS will operate, approval of the 

application presents no national security issue. Given the clear direction in Section 333 of the 

Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong 

equivalent level of safety, surrounding the proposed operations, and significant public benefit, 

including enhanced safety, reduction in environmental impacts, including reduced emissions 

associated with allowing UASs for movie and television operations, the grant of the requested 

exemptions is in the public interest. Accordingly, the applicant respectfully requests that the 

FAA grant the requested exemption without delay. 

2 The Flight Operation Manual is presented as an applicant Confidential document under 14 CFR 11.35 

(b) as the entire manual contains proprietary methods and information that the applicant has not and will 

not share with others. The manual reflects learned experiences, methods, operating conditions, and 

procedures that are not available to the public and are protected from release under the Freedom of 

Information Act 5 USC 552 et.seq. 

4Reform Act Section 333 (b) 
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at 

least an equivalent or even higher level of safety to operations under the current regulator 

structure because the proposed operations represent a safety enhancement to the already safe 

movie and television filming operations conducted with conventional aircraft. These limitations 

and condition to which Air Renditions Videography agrees to be bound when conducting 

commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and aircrew 

(Spotter / Observer, Camera / Sensor Operator).

3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be 

terminated at 25% battery power reserve should that occur prior to the 30 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet 

above an elevated platform from which airborne data collection is planned.

5. Minimum two (2) man crew for each sUAS operation will consist of the Pilot and Spotter / 

Observer. In most cases the third aircrew member will serve as the Camera / Sensor Operator.

6. The sUAS Pilot will be an FAA licensed airman with at least a private pilot’s certificate and 

third class medical. The Camera / Sensor Operator and Spotter (Observer) will hold at least a 

third class medical.

7. The sUASs Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder other than 

the sUAS Pilot, who possess the necessary PIC qualifications, is also present on set (i.e. the 

Aerial Coordinator), that person can also be designated as PIC.

8. The sUASs will only operate within a confined “Sterile Area” as defined in the Manual. 

Section D of the Manual requires the establishment of a “Security Perimeter” for the flight 

operations areas. 

A pre-flight briefing will be conducted in regard to the planned sUAS operation prior to each 

day’s production activities. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the safety perimeter be present for this briefing. 
10. The Operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate Flight Standards District Office (FSDO). 

11. The Operator will obtain the consent of all persons involved in the filming and ensure that 

only consenting persons will be allowed within 100 feet of the flight operation, and this radius 

may be reduced to 30 feet based upon an equivalent level of safety determination, as required by 

Appendix A.3 of the Manual. With the advanced permission of the relevant FSDO, operations at 

closer range can be approved. 

12. The Operator will submit a written Plan of Activities to the FSDO three (3) days before the 

proposed shoot as required by Section E of the Manual. 

13. Pilot, Camera Operator, and Spotter (Observer) will have been trained in operation of sUAS 

generally and received up-to-date information on the particular sUASs to be operated as required 

by Section J and Section 2. B of the Manual. 

14. Spotter (Observer) and Pilot will at all times be able to communicate by voice, radio, and/or 

text. 

15. Written and/or oral permission from the relevant property holders will be obtained. 

16. All required permission s and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

17. If the sUASs loses communications or loses its GPS signal, the sUASs will have capability to 

return to a pre-determined location within the Security Perimeter and land. 

18. The sUASs will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a)

(1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 
Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 

333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement 

capability, and proximity to airports and populated areas of the particular UAS. In all cases, an 

analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as 

safe, or safer, than a conventional aircraft (fixed-wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

The sUASs to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively 

within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this 

exemption will be tightly controlled and monitored by both the Operator, pursuant to safety 

requirements, and under the requirements and in compliance with local public safety 

requirements, to provide security for the area of operation as is now done with conventional 

filming. The FAA will have advance notice of all operations. These safety enhancements, which 

already apply to civil aircraft operated in connection with motion picture and television 

production, provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 

21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load. 

Page Eight 14 CFR §45.23 (B): Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter “N” and the registration number is displayed 

on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” 

“restricted”, “light-sport,” “experimental,” or “provisional,” as applicable. 

Even though the sUASs will have no airworthiness certificate, an exemption may be needed as 

the sUASs will have no entrance to the cabin, cockpit or pilot station on which the word 

“Experimental” can be placed. Given the size of the sUAVs, two-inch lettering will be 

impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 

(f). 
The equivalent level of safety will be provided by having the sUAVs marked on its fuselage as 

required by §45.29 (f) where the Pilot, Spotter (Observer) and others working with the sUAVs 

will see the identification of the UAS as “Experimental.” The FAA has issued the following 

exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitations - Pilot in Command (PIC) 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s 

license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional 

aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing 

on board. The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the Manual. The level of safety provided by the 

requirements included in the Manual exceeds that provided by single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of the 

sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 

14 CFR §61.113 (a) & (b). 

14 CFR §91.7 (a): Civil Aircraft Airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the requirements contained in the Manual for maintenance and 

use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent 

level of safety will be provided. 

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... 
2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof. 

The sUAS, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the ground 

control point where the pilot flying the sUAS will have immediate access to it. The FAA has 

issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A 10602, 32827, and 10700 

14 CFR §91.103: Preflight Action 

This regulation requires each pilot in command to take certain actions before flight to insure the 

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft 

an exemption will be needed. An equivalent level of safety will be provided as set forth in 

Sections J and K of the Manual. The PIC will take all actions including reviewing weather, flight 

battery requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight. 

14 CFR §91.109: Flight Instruction 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. SUASs and remotely piloted aircraft, by their design do not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that communicates with 

the aircraft via radio communications. The FAA has approved exemptions for flight training 

without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. See Exemptions Nos. 5778K & 9862A. The equivalent level of safety 

provided by the fact that aircraft. 

14 CFR §91.119: Minimum Safe Altitudes 
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a sUAS that is a fixed-wing or rotorcraft requests authority to operate at 

altitudes up to 400 ft. AGL, or not more than 200 ft. above an elevated platform from which 

filming is planned, an exemption may be needed to allow such operations. As set forth herein, 

except for the limited conditions stated in the Manual, the sUASs will never operate at higher 

than 400 ft. AGL. It will however be operated in restricted area with security perimeter, where 

buildings and people will not be exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the sUASs as 

well as location where it is operated. No flight will be taken without the permission of the 

property owner or local officials. Because of the advance notice to the property owner and 

participants in the filming activity, all affected individuals will be aware of the planned flight 

operations as set forth in Section K of the Manual. Compared to flight operations with aircraft or 

rotorcraft weighing far more than the maximum 55 lbs. proposed herein and the lack of 

flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 ft. AGL in the movie industry. In 

addition, the low-altitude operations of the sUASs will ensure separation between these small 

sUASs operations and the operations of conventional aircraft that must comply with Section 

91.119. 

14 CFR §91.121: Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, 

but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety 

will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. 

14 CFR §91.151 (a): Fuel Requirements for Flight in VFR Conditions 
Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing, and, assuming normal cruising speed – (1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” 

The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet 

the 30 minute reserve requirement in 14 CFR §91.151, sUASs flights would be limited to 

approximately 10 minutes in length. Given the limitations on the UAS’s proposed flight area and 

the location of its proposed operations within a predetermined area, a longer time frame for flight 

in daylight or night VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where 

only people and property owners or official representatives who have signed waivers will be 

allowed, with less than 30 minutes of reserved fuel, does not engender the type of risks that 

Section 91.151 (a) was intended to alleviate given the size and speed of the small UAS. 

Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the 

exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 

minutes or 25% of battery power whichever happens first. This restriction would be more than 

adequate return the sUAS to its planned landing zone from anywhere in its limited operating 

area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808. 

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it 

the following: 

(1)An appropriate and current airworthiness certificate...
(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (b) of this section or a special flight authorization issued under §91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard Pilot. As 

such, there is no ability or place to carry certification and registration documents or to display 

them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control 

point where the Pilot flying the sUAS will have immediate access to them, to the extent they are 

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700. 

14 CFR §91.405 (a); 407 (a) (2); 417 (a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph © of this section, have discrepancies repaired as prescribed in Part 43 of this 

chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. Maintenance will be accomplished by the operator 

pursuant to the flight manual and operating handbook as referenced in the Manual. (See Sections 

L and Q) An equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in restricted areas for limited 

periods of time. If mechanical issues arise the UAS can land immediately and will be operating 

from no higher than 400 ft. AGL. As provided in the Manual, the operator will ensure that the 

UAS is in working order prior to initiating flight, perform required maintenance, and keep a log 

of any maintenance performed. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the 

equivalent level of safety. 

********* 

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 
14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 

91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.405 (a); 91.407 (a) (1); 

91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or 

less) in industrial, motion picture and television operations. 

Privacy 

All flights will occur over private or controlled access property with the property owner’s prior 

consent and knowledge. Image capture of people will rarely take place, but in the event they are, 

they will have consented prior to being filmed or otherwise have agreed to be in the area where 

data collection will take place. 

Airborne Image Capture (Day & Night) 

With regard to airborne filming, Air Renditions Videography adheres to all FAA regulations. 

Further AWI airborne teams operate under the principals of: Safety First, Quality Assurance, 

Accountability, Reporting, and Training. When approved by the FAA it is AWI’ mandate to treat 

all sUASs operations the exact same as that of conventional aircraft. 

Approval of exemptions allowing commercial operations of sUASs in the film industry will 

enhance safety by reducing risk. Conventional film operations, using jet or piston powered 

aircraft, operate at extremely low altitudes just feet from the subject being filmed and in extreme 

proximity to people and structures; and present the risks associated with vehicles that weigh in 

the neighborhood of 4,000lbs., carrying large amounts of Jet A or other fuel (193 gallons for jet 

helicopter shown below). Such aircraft must fly to and from film location. In contrast, a sUAS 

weighing fewer than 55lbs. (Inspire 1 travel case shown below) and powered by batteries 

eliminates virtually all of the risk given the substantial reduced mass and lack of combustible 

fuel carried on board. The sUAS is typically transported to the location via auto or cargo van in a 

medium sized case and is never flown to set. The sUAS will carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights. 

INSPRIRE 1 – SINGLE CASE W/ DUAL CONTROLLERS ASTAR 355 W/IR SENSOR MOUNTED ON TYLER SIDEMOUNT

The operation of small UASs, weighting less than 55lbs., conducted in the strict conditions 

outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 and 

allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the 
ground, and in a sterile environment and, as a result, are far safer than ground than conventional 

operations conducted with turbine helicopters operating in close proximity to the ground and 

people. 

DAMAGE ASSESSMENT - CELLULAR TOWER POWER LINE - HIGH VOLTAGE SUB-STATION 

The primary market of interest for AWI utilizing sUASs is the visual inspections of 

telecommunications towers and secondary is power lines. To simulate sUAS aircraft flying at 

below 400 feet AWI has conducted manned aircraft data collections utilizing gyro-stabilized 

systems (i.e., CineFlex, Wescam) with standard long telephoto lenses. In the cellular tower sector 

it is estimated the use of sUAS aircraft will reduce hazardous tower climbs by as much as forty 

percent (40%). Aside from reducing the number of physical climbs, the utilization of sUAS will 

dramatically lower the use of cranes and lifts, which also pose dangerous conditions for build 

and repair personnel. In a number of instances, inspectors just need to get “eyes on” the tower 

top assemblies to look for specific deficiencies. With regard to power lines when climbers are 

sent in the power must be deferred. The use of sUAS may allow these industries to fill in the data 

gaps where traditional aircraft are currently restricted. In addition AWI is conducting 

engineering research with local universities addressing a number of sUAS concerns (i.e., RF 

shielding, flight control range). 

It is anticipated that the airborne image capture process will be accomplished in both day and 

night environments. Currently, conventional aircraft are flown in highly populated and/or urban 

areas, with turbine powered helicopters. The grant of this exemption request will provide 

improved safety in both day and night operations. To capture the highest quality of resolution the 

majority of airborne data collections will take place during the 10:00am – 4:00pm window. 

There may be night operations conducted where infrared sensors will be deployed. If such 

operations are required the ground facilities and the subject tower assemblies may require 

additional lighting so that visibility is as though it was conducted during daylight hours. 

Summary 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within 

visual line of sight and national security – provide more than adequate justification for the grant 

of the requested exemptions allowing commercial operation of applicant’s sUAS in the 

industrial, motion picture and television production industry pursuant to the Manual appended 

hereto. AWI is eagerly standing by to support the FAA and sUAS community in its quest to 
establish proper regulations and protocols for the safe introduction of unmanned aircraft into the 

national airspace. 

Sincerely, 

Rich Galagaran CEO 

Tim Thompson CTO 

Air Renditions Videography 

1294 Lynwood Dr. Novato, CA 94947 

415-895-6634 

www.airrenditions.com